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Achilles UVDB Verify B2 Audit Report

Westwell Developments Ltd

Date of Audit: 9th and 10th August 2017

Auditor: Rasib Hussain

services for professional procurement

www.achilles.com

14/11/2016 UVDB/QS/003 UVDB Verify B2 Protocol Version 10.3

Supplier ID: 61812 Supplier Name: Westwell Developments Ltd

Auditor(s): Rasib Hussain Address: Whitewall Road, Rochester, Kent,

ME2 4DZ

Tel: 01634 726148 Site Address (first line

only)

De La Rue Currency, Overton Mill,

Overton

Audit

Date(s):

9th and 10th August 2017 Contact Name: Ben Gordon-Smith

Title: Managing Director

Introduction:

.

MSE Percentage Score Site Percentage Score

96% 97%

93% 100%

89% 100%

76% 100%

.

88% 99%

CSR

Average Amalgamated Scores

EXECUTIVE SUMMARY

The company operate across the United Kingdom and their activities include plant installations and major machines rebuilds,

on-site machining, refurbishment and general maintenance of plant and machinery and specialist optical alignment surveys

within the UK. The company have approx 20 direct employees and around 7 self employed contractors.

The scope of the works included the installation of ISRA equipment and ancillary equipment at a large paper mill. There were

around 3 personnel who were working at this site using heavy plant such as a the overhead crane, small hand tools and

equipment.

There was no critical non-compliances, 1 x major non-compliance, 17 x minor non-compliances and 4 x observations that

were recorded.

AMALGAMATED SCORES

Health & Safety

Environment

Quality

Achilles UVDB Verify B2 Protocol Version 10.0

.

Section

NumberSection MSE Percentage Score Site Percentage Score

System Assurance and Compliance,

Quality Assurance100%


Health & Safety100%


Environmental Management100%

2 Quality Control and Assurance 93% 100%

3 Business Integrity and Ethics 83% 100%

4 Employment Practice and Human Rights 50%

5Training and Capability/Competence

Assessment100% 100%

6 Working Hours 100%

7 Workplace Safety 86% 83%

8 Occupational Health 83%

9 Emergency Planning 100% 100%

10 Site Security 100% 100%

11 Business Continuity 67%

12 Environmental Management 73% 100%

13 Carbon Management 100%

14 Waste Management 100% 100%

15Selection and Management of the Supply

Chain83%

16 Sourcing of goods and products 93%

17Use of Work Equipment, Vehicles and

Machines100% 100%

18 Insurance and Warranty 100%

1


Question

NumberFinding

NA None identified.

Question

NumberFinding

4.1

The company did not have standard processes to verify right to work in the UK checks were

made for all employees.

Question

NumberFinding

2.1 The quality policy statement was un-signed.

2.8A central non-conformance register was not maintained.

3.1 An anti-bribery policy was being established and was in draft format.

7.4The company did not have measurable health and safety targets.

7.6 Health and safety meetings were not formalised.

7.7The company did not have a behavioural safety programme or reward initiative.

7.8 PPE was issued free of charge but was not always formally recorded.

7.9The company had a range of COSHH items although an accurate central COSHH register was

not fully established.

8.2 The use of health questionnaires and DSE assessments were not evident.

11.1 A formal business continuity plan was not established.

12.1

The environmental policy statement was not detailed when it was last reviewed or if it was made

available to the public on request and appeared generic.

12.2

The environmental management system did not clearly take into account design process

controls.

12.4

The aspects and impacts register did not contain expansive control measures and did not

contain the Assessors name.

12.5 Specific internal environmental audit programmes and audits were not always carried out.

15.1

Contractor supplier questionnaires were sampled although these did not include a signed off by

internal senior management.

15.4 The company does not currently carry out any inspections or audits of their supply chain.

16.3The company did not have a formal process to validate how they worked to prevent anti-bribery

with their supply chain.

Question

NumberFinding

1.1 The company may wish to operate 3rd party certified HSE management systems.

2.6The company did not have third party certification such as ISO 27001 Certification - Information

Security Management and may wish to review this.

7.3 There was no internal NEBOSH or equivalent certified personnel.

16.1 There was no specific awareness of CFSI although the company do not work in the nuclear

industry.

Critical Non-Compliances

Major Non-Compliances

Minor Non-Compliances

Observations

Question

NumberFinding

NA None identified.

Question

NumberFinding

NA None identified.

PQQ Discrepancies

Positive Elements

1.0 System Assurance and Compliance MSE SITE

1.1 Can the company demonstrate that their Quality Management Systems are

assured? 3

Can the company demonstrate that their Health & Safety Management Systems

are assured? 3

Can the company demonstrate that their Environmental Management Systems

are assured? 3

The Auditor shall establish:

Does the company have any formal 3rd party certification for their management systems

as awarded by an independent accreditation body for quality, health and safety,

environment or social responsibility?Y

Does the company’s accreditation apply to more than one country if the company has

international operations? (if yes please detail countries) N

Is the accrediting body registered with the UKAS or other international equivalent?N

Where 3rd party accreditation has not been achieved is the company prepared to operate

adopt their clients Quality, Health & Safety and Environmental Management Systems? Y

Question Evidence:

The company has 3rd party certified quality systems (ISO:9001) but not for their HSE

management systems. Whilst the HSE Management systems are not assured to a

recognised standard it does contain all of the key components and is subject to periodic

review.

Observation: The company may wish to operate 3rd party certified HSE management

systems.

Documents Presented

3rd party certificate provided and reviewed (QMS certificate No. GB4886, expiry date the

27th February 2019 to ISO 9001:2008).


CQ1.2 Can the company demonstrate compliances with the Construction, Design and

Management Regulations? 3


Does the company undertake any activities that fall under the CDM regulations?Y

Has the company identified and documented its responsibilities as defined within the CDM

regulations e.g. Principal Designer, Designer, Principal Contractor?Y

Do company management systems clearly identify processes for meeting and discharging

duties as required by the CDM regulations? Y

Question Evidence:

The company were aware of the CDM Regulations 2015 and had procedures in place to

comply with the CDM Regs 2015.

Documents Presented

CDM procedure in H&S manual and legislation referenced in page 14.

1.3 Has the company identified all permit and licensing requirements applicable to

the scope of services provided? 3


Has the company identified the necessary licenses and permits applicable to the scope of

services provided? NA

Can the company demonstrate that all applicable licenses and permits are held and in

date? NA

Can the company demonstrate it is implementing the requirements of each permit or

license that is held? NA

Question Evidence:

At the time of the assessment the company did not require specific licenses.

Documents Presented

Section Score15

2.0 Quality Control and AssuranceMSE SITE


2.1 Does the company have a formally approved Quality Management policy

statement? 2


Is the policy statement signed and endorsed by the most senior management

representative? N

Does the policy relate to the company activities? Y

Is the period for review documented?Y

Question Evidence:

The quality policy statement was un-signed. The policy statement was confirmed as being

reviewed annually.

Minor non-compliance: The quality policy statement was un-signed.

Documents Presented

Quality policy statement dated 2017.

2.2 Has the company formally appointed a representative who has responsibility for

Quality management within the company? 3


Have the competency requirements been clearly documented?Y

Has responsibility been formally assigned and recorded?Y

Question Evidence:

The Managing Director was responsible for functional quality assurance matters. These

responsibilities were documented in the quality manual.

Documents Presented

Quality manual dated 2017.


2.3 Does the company use processes or systems for the management and control of

documentation? 3


Is there a documented management procedure for document control?Y

Does the Document Control system identify the key documents requiring managementY

Is there a process in place for withdrawing and re-issuing of updated documents?Y

Does the process include document archiving? (Is there a retrieval process for the

archived document) Y

Is there a process or system in place for the secure disposal of confidential

documentation? Y

Is there a master list of controlled documents?Y

Question Evidence:

A defined document control procedure was available as a stand alone procedure and a

basic list of controlled documents was evident from reviewing the company's audit

prepared documents.

Documents Presented

Document list and procedure dated 2016.

2.4 Does the company have documented processes for the control and production of

Q.C. (Quality Control) Plans /Procedures /Inspection documentation / Testing

documents and competence of staff involved?3

That specific Quality Control documentation (as applicable) is included within the company

document control processes. Y

Whether the company undertakes any analysis to monitor the effectiveness of the

procedures in place? Y

Question Evidence:

Activity-related quality control documentation was managed through a defined document

control procedure. This extended to site works, contracts and project documentation.

Documents Presented

Completed works inspection sheet: CR005.



2.5 Does the company have a controlled and documented process for the hand over

of completed works? 3 3


That the company manages the documentation and process of completion of agreed

contractual work. Y Y

Does the company specify how long handover records will be retained?Y Y

Question Evidence:

Before acceptance of a contract or order, the company ensured the client requirements

were defined and documented. The process was demonstrated through reviewing

procedures and project documents.

Documents Presented

Method statements dated 2017.


Site file includes drawings.

2.6 How does the company guarantee the confidentiality, availability, and integrity

of information and supporting IT systems? 3


Does the company have third party certification for IT management? e.g. ISO/IEC 27001 N

Is electronic information backed up on site or remotely?Y

Does the company utilise a third party to store confidential data? Y

Does the company have protective systems in place to reduce the occurrence of malicious

software/IT downtime? Y

Does the company have a process or procedure relating to the back up of confidential

data? Y

Question Evidence:

The company confirmed that they have firewall and virus protection and the Office

Manager had access to external IT support.

Observation: The company may wish to consider third party certification such as

ISO/IEC 27001.

Documents Presented

Pinnacle - IT Support.


2.7 Does the company have in place an internal auditing/inspection programme?3 3


Are the audits at regular/programmed intervals?Y Y

That the company has specified a minimum competency level for personnel undertaking

audits / inspections. Y Y

Does the company ensure all areas of the business are covered by this programme?Y Y

Does the internal audit process include contract / customer specific requirements?Y Y

Question Evidence:

Internal audits were undertaken as per the audit schedule with the Quality Reps being the

Internal & External Audit Representatives. A sample audit and schedule from 2017 was

provided.

Documents Presented

Internal audit reports carried out at dated Jan 2017.

Internal audit programme reviewed dated 2017.

QMS audit report dated 05/09/2016.

2.8 Does the company have a management process in place to review non

conformities/findings identified within: first, second and third party audit

programmes?2


Are key personnel assigned to ensure findings are closed out?Y

Is a register kept of all outstanding issues and is it subject to regular review?N

Does the company have a mechanism in place to manage the close out of audit

outcomes? Y

Does the company have a mechanism in place to ensure assessor that defects / NCRs are

closed out to satisfy applicable designs / specifications? Y

Question Evidence:

The company used various formal mechanisms to control any non-conforming products

and services. Evidence was provided of an internal audits as well as a customer feedback

log book. Although there was no evidence of a central non-conformance register.

Minor non-compliance: A central non-conformance register was not maintained.

Documents Presented


2.9 Does the company utilise information /data obtained as a result of the internal

audit/inspection programme to improve business process? 3


Is analysis of evidence/findings communicated to the relevant departments/nominated

management representatives as part of an overall improvement programme? Y

Is the information communicated to stakeholders /shareholders and the management

team (Post Analysis)? Y

Question Evidence:

Management meeting minutes were reviewed. This document did contain number of

attendees and 5 standard items on the agenda.

Documents Presented

Management meeting minutes dated June 2017.

Section Score25 6

3.0 Business Integrity and Ethics

3.1 Does the company have a formal procedure in place in the event a member of

the workforce breaches company rules regarding bribery, soliciting for money,

intimidation or extortion for monetary gain in order to influence decision

making?

2

Does the procedure define a clear and logical structure of how the company would deal

with potential problems such as this? Y

Would the company involve the police in the event the policy is breached?Y

Do workers sign a declaration agreeing that they have read and understood the content

and will abide by the policy? N

Question Evidence:

The company did not have expansive live procedures to deal with anti-bribery and

corruption. Although a new process was in development and was in draft format. This was

provided by the Office Manager.

Minor non-compliance: An anti-bribery policy was being established and was in draft

format.

Documents Presented

Draft anti-bribery policy reviewed.


3.2 If a worker advises senior management of improper conduct either as a result of

corruption, bullying/harassment, breaches of safe working practice,

environmental issues; can the company demonstrate that the worker would be

protected and the information treated confidentially (whistle blowing policy)?3 3


Is there a formal process / procedure that demonstrates how a worker can make a formal

complaint in confidence? Y Y

Is the complaint reported to an independent party?Y Y

Can the company demonstrate how the policy has been communicated to all categories of

worker? Y Y

Question Evidence:

The company provided evidence of their whistle blowing policy which was made available

to employees in a handbook.

Documents Presented

Whistle blowing policy page 20 & induction records dated May 2017.

Section Score5 3


4.0 Employment Practice and Human Rights

4.1 Is there a process or system to ensure that personnel recruited are entitled to

work in the country of operation? 1


Can the company demonstrate understanding of the relevant laws regarding the

employment of workers who are not from the country of operation? N

Are all legal requirements followed when employing workers who have the legal ability to

work within the country of operation e.g. as specified through the Asylum, Immigration

and Nationality Act?N

Is evidence used to validate the individual’s identity and eligibility to work such as; birth

certificates, passports, identity cards, social security numbers etc.? (Please detail and if

copies are retained)Y

Does the company retain evidence of entitlement to work for at least 3 years after the

individual has left the employer? (Specify if a different period and if this covers temporary

workers)N

Were personnel files available for sampling?Y

Question Evidence:

The company provided evidence of an employee file. The random selected employee had

not provided information to verify right to work in the UK as only a copy of a driving

licence was taken. It appeared that the company reviewed identification based on where

the employee would be working e.g. high security client site required passport but not for

all employees.

Major non-compliance: The company did not have standard processes to verify right to

work in the UK checks were made for all employees.

Documents Presented

New starters dated 18/05/2017.


4.2 Are all employees including temporary or seasonal workers issued with a

contract containing details of their employment? 3

Were personnel files available for review and to validate that workers are issued with a

contract detailing information about their employment terms, payment, and type of

employment and working hours including temporary or seasonal workers? (Please detail) Y

Question Evidence:

The company confirmed that they issue all employees with contracts of employment and

there was evidence to support this.

Documents Presented

New starter dated May 2017 reviewed with a contract of employment.

4.3 Does the company use employment agencies or labour companies?3


Does the supplier verify the competencies/capabilities of all agency-supplied labour prior

to being supplied to them? Y

Does the company have a process to ensure that agency personnel have not worked

hours in excess of legislative and regulatory limits before attending their work site? Y

If workers are utilised via recruitment agencies or labour companies, are checks made to

verify that all workers are entitled to work in the specified country? Y

Question Evidence:

The company confirmed that they do use the services of employment agencies and any

agency staff were subject to the same company inductions and processes as employees.

Documents Presented

Induction records dated May 2017.


4.4 Are trade unions present within the company?3

Which Unions are represented within the company?N

If no unions are allowed, this is to be recorded and a reason provided by the company.NA

If no unions are allowed, does the company prevent workers from forming any other

mechanism for collective bargaining? N

Question Evidence:

The company confirmed that they do not have any trade unions represented in the

company but would allow representation if employees required it.

Documents Presented

4.5 Has the Organisation prepared and published an annual Slavery and human

trafficking statement?3

The Auditor should establish the following:

The organisation has developed an annual statement related to slavery and human

traffickingN

The statement is appropriately approved and signed off N

The statement is published / available via:

a) The organisation's website, a link to it must appear in a prominent place on the

homepage,

or

b) If the organisation does not have a website, it must provide a copy of the slavery and

human trafficking statement to anyone who makes a written request for one, and must do

so before the end of the period of 30 days beginning with the day on which the request is

received.

N

Question Evidence:

The company had a turn over of less than £36 million and did not have a modern slavery

and human trafficking policy statement.

Documents Presented

Section Score13


5.0 Training and Capability/Competence Assessment

CQ

5.1 Does the company induct new workers into the business when they first start on

site? (This should include employees, sub-contractors, self employed and

visitors)3 3


Are records of induction held?Y Y

What mechanisms are used for induction delivery?

That the induction process covers at least:

Company structureY Y

Roles and responsibilitiesY Y

Training and competency requirementsY Y

Relevant legislative and regulatory requirementsY Y

Site-specific requirements e.g. welfare facilities/safety risksY Y

Emergency procedures e.g. warning signals/first aid issuesY Y

Code of ConductY Y

Accident/hazard reporting - what to doY Y

Is there a documented period for re-inducting / re-briefing personnel and applicable

personnel? Y Y

Question Evidence:

The company provided evidence of their employee induction programme packs that

covered a range of training such as company policies and procedures.

Documents Presented

Induction programmes packs reviewed x 3 employees dated 2017.


5.2 Has the company identified all work activities relating to their scope of service

that requires formal training? 3 3


Is a training matrix is in place for all categories of worker?Y Y

If the company does not utilise a matrix format do they have any other system to record

what training is required for each job? Y Y

Does the training process confirm competency/capability requirements as well as training

needs? Y Y

What systems does the company have in place to identify new training requirements

relating to changes in scope of services being provided?

Question Evidence:

The training needs of employees were identified and recorded on a training matrix and on

an additional database. The data base allowed a search function under the employee

name.

Documents Presented

CCNSG safety passport card scheme training expires 17/06/2018.

5.3 Is there a system in place to ensure that existing training certificates /licences

held by individuals are checked and validated on a regular basis? 3


Are licences for operating plant and equipment or for specific trades checked for validity

when presented by new workers joining the company who already possess the

certification?Y

Does the company have a means of identifying certification expiry/re-training dates and

also, where necessary, competency assessment due dates?(Can be electronic/manual or

notification by training organisation)Y

Question Evidence:

In accordance with the company's written procedure for re-certification of all personnel

was carried out prior to the validity of an authorisation expiring. Re-certification was

achieved through either: external or internal training.

Documents Presented

CCNSG safety passport card expires 27/07/2017.

Confined Space Training dated Sept 2015.

Overhead Crane Certificate dated 21/11/2013.


5.4 Has the company defined training standards for its workforce based on in-house

or national /industry standards? 3


Are the levels required by the company documented?Y

Where competency/capability standards have been developed; are they signed off by a

competent professional or Head of Department? Y

Does the programme cover all categories of worker?Y

Does the company use a numerical process to evaluate a workers capability when

progressing against a specific standard? E.g. pass marks, matrix approach with cumulated

scores to meet specific standard.Y

Question Evidence:

The company provided evidence of their employee training records that demonstrated

that employees had attended some form of training. Training was approved by line

management.

Documents Presented

Training register dated 2017.

5.5 Does the company have programmes in place for the re-assessment/re-training

of personnel? 3


Is there a schedule for re-assessment?Y

Are personnel records up to date (Auditor to take a sample)?Y

If reliant on an external party, is there a system in place to monitor the effectiveness of

the company used? Y

Are remote (Individuals who work on sites or areas away from the main head office e.g.

site tradesperson, lorry drivers) workers advised of their need to be re-assessed? Y

Does the company monitor the effectiveness of the training programmes provided?Y

Question Evidence:

Staff competencies were detailed on the training database and any expired training was

flagged through this process. The company had evaluated the effectiveness of external

training through the use of evaluation forms.

Documents Presented

Training register dated 2017.

Section Score15 6


6.0 Working Hours

6.1 Does the company keep records of all workers standard and overtime working

hours? 3

Are time sheets subject to accuracy checks?Y

Provide details of all shifts and days worked including any differences by other categories

of staff e.g. security work longer hours than office /white collar staff. Y

Specify average working weekY

Does the company experience peaks and troughs throughout the year where working

hours fluctuate? (Specify timescales) Y

Is any overtime undertaken on a voluntary basis?Y

Question Evidence:

The company provided evidence that all employee working hours were recorded on

weekly time sheets. Overtime was undertaken on a voluntary basis and required formal

approval from the management. The company confirmed that they ensured adequate

personnel were available to avoid having peaks and troughs in workload due to any busy

periods. The average working hours appeared to be around 45 hours per week.

Documents Presented

Timesheets reviewed dated June & July 2017.

Section Score3


7.0 Workplace Safety

CQ7.1 Does the company have established processes to ensure compliance to legal and

other legislative requirements that are applicable? 3


Demonstrate organisational subscriptionsY

Has the company established, implemented and maintained procedures to identify and

access all legal and other requirements. Y

Question Evidence:

The company had access to competent external safety advice and had access to

information from their documented legal register which was detailed in the H&S manual.

Documents Presented

Peninsula H&S manual.


7.2 Does the company have a policy statement relating to the provision of a safe

working environment? 3 3

Does it demonstrate a commitment to continually improving workplace safety?Y Y

Does the policy extend to not only workers but also third parties and people who are not

employed but may be affected by the company’s activities? Y Y

Is it endorsed and supported by the most senior management within the company?Y Y

Is the policy on display anywhere within the company? Poster/intranet etc.Y Y

Is the policy and its contents formally issued to employees, subcontractors and suppliers?Y Y

Question Evidence:

The company provided evidence of their H&S policy statement and this was signed by the

Managing Director and reviewed annually. The policy statement was made available to all

company personnel.

Documents Presented

Policy statement dated 25/07/2017.

7.3 Does the company have a person who has delegated responsibility for workplace

and product safety? 3

Are the corporate responsibilities for this person defined in a job description?Y

Does the delegated person holds qualifications / professional memberships appropriate to

the role e.g. Nebosh / IOSH / IIRSM? N

If the company is part of a larger group is there a corporate reporting structure from the

local facility to the Group Head responsible for Safety? NA

Does the company split the responsibility for workplace and product safety? (Specify how

this works) N

Question Evidence:

The Managers were delegated with the functional responsibility for workplace safety. They

had external competent support although no internal staff had the NEBOSH General

Certificate or equivalent.

Observation: There was no internal NEBOSH or equivalent certified personnel.

Documents Presented

Peninsula H&S support and manual.


7.4 Can the company demonstrate that the senior management team take a

proactive role in the continuous improvement of health, safety and industrial

hygiene within the company?2 2

Does senior management take part in random and programmed safety

inspections/tours/audits? Y Y

Does the company commit to establishing measurable objective and targets to ensure

continued improvement aimed at elimination of work related injury and illness? N N

Is there evidence to support performance monitoring of these objectives? N N

Question Evidence:

The company did not have measurable health and safety targets although periodic

inspections by the General Manager were evident.

Minor non-compliance: The company did not have measurable health and safety

targets

Documents Presented

Managers Periodic Health and Safety Checklist dated the May 2017 carried out by the

General Manager.

CQ7.5 Does the company have control measures in place to reduce / remove identified

Health and Safety Risks 3 3


Has the organisation established, implemented and maintained documented procedures to

identify hazards/impacts and assess risks? Y Y

Has the company developed its methodology for hazard identification, risk assessment

and risk control, based on operational experience? Y Y

Does the company use all forms of Risk Assessment including; Generic, Dynamic, site

specific etc.? (Auditor to detail the risk control processes in place) Y Y

Does the company have a process to manage works completed under a permit to work

system issued by the company or by a principal contractor? Y Y

Question Evidence:

The company provided evidence of their risk assessments for their activities such as site

works and these were fully completed and signed off. The risk assessments followed a

methodology of hazard identification, consequence and control measures implementation.

A job was reviewed and this included the scope of works and the safety arrangements.

This included feedback on risks and additional controls.

Documents Presented

Risk assessments dated June & July 2017.

Method statement for De La Rue & DS Smith Kemsey Mill.


CQ7.6 Does the company have a communication process to provide guidance to the

workforce on workplace safety issues? 2 2


Does the company utilise a variety of different methods of communication? (Specify

methods used) Y Y

Does the company keep a formal record of all communication/briefings issued?Y Y

Does the company verify that mechanisms for communication with personnel with poor /

non-local language skills are appropriate and that hazards are understood? Y Y

How does the company ensure subcontractors are included within briefing and

communication programmes? Y Y

Does the company have forums / committees / groups or other mechanisms to enable the

communication and discussion of safety issues? N N

Question Evidence:

The company stated they had the following communication methods: informal meetings;

inductions; hand-outs; notice boards; database access and tool box talks.

Minor non-compliance: Health and safety meetings were not formalised.

Documents Presented

Tool box talks dated 2016 & 2017.

7.7 Does the company develop and implement initiatives to improve workplace

safety? 2 2


Can the organisation demonstrate how it identifies and quantifies areas of improvement

relating to Health & Safety? Y Y

Can the organisation demonstrate how it develops programmes to rectify and improve

upon Health & Safety performance? Y Y

Are workers rewarded for developing and implementing workplace safety initiatives? (Can

be financial/award of gifts etc.) N N

Does the company have a Behavioural Safety programme in place?N N

Question Evidence:

The company had implemented their health and safety tool box talks and client site

safety improvement initiatives.

Minor non-compliance: The company did not have a behavioural safety programme or

reward initiative.

Documents Presented

Tool box talks 2017 & site documents.


CQ

7.8 Can the company demonstrate that they issue appropriate Personal Protective

Equipment (PPE) to all workers (migrant workers, contract/ labour, full-time)

that may be exposed to workplace hazards?2 2


Were issue lists provided as evidence?N N

Can the company demonstrate that all workers have been given guidance on the proper

handling, storage and use of PPE? Y Y

Is there a period of time for the retention of PPE records?Y Y

Is there a methodology used to identify type of equipment that needs to be used?Y Y

Does the company issue agency labour with PPE (with records of issue retained) or if not

does the company retain records of inspection of Agency labour PPE documenting that it

meets the company’s standards and legislative requirements? Y Y

Is there a disciplinary procedure linked to failure to wear required PPE?Y Y

When self employed workers/ sub contractors attend site with their own equipment does

the company check its suitability? Y Y

Can the company demonstrate that all PPE is issued free of charge to all workers?Y Y

Question Evidence:

The company issued free of charge all PPE to staff in accordance with identified

procedures.

Minor non-compliance: PPE was issued free of charge but was not always formally

recorded.

Documents Presented


7.9 Can the company demonstrate that they have assessed the hazards associated

with applicable chemicals and/or hazardous substances? 2 2


Does the company have a process or system in place to ensure that up to date data

sheets are obtained? Y Y

Are all copies of data sheets retained in a register?N N

Does the company have a process for ensuring MSDS and supporting assessments are

available to the emergency services (including first aid trained personnel) where

necessary?Y Y

Question Evidence:

The company maintained procedures which define the requirements for assessing

substances hazardous to health and establishing safe limitations on their use.

Minor non-compliance: The company had a range of COSHH items although an

accurate central COSHH register was not fully established.

Documents Presented

COSHH assessments for Molyslip dated 02/02/2015.


7.10 Is there a system in place for the correct handling and storage of hazardous

substances and goods? 3 3


Is there any site storage of flammable materials including fossil fuels/LPG/auto gas?Y Y

Can the company demonstrate they utilise appropriate containment on site needed to

retain leakage from storage vessels? (Bunds/Reinforced walls) Y Y

Is there a programme in place to assess the integrity/suitability of the storage areas?Y Y

Does the company employ a No Smoking policy in open areas?Y Y

Does the company have spill kits available for use?Y Y

Question Evidence:

The company advised that they do store fuels and gases at their head office and

inspections were carried out.

Documents Presented

Inspection dated May 2017 reviewed.

7.11 In the event of an injury in the workplace can the company demonstrate they

have adequate emergency first aid facilities onsite? 3 3

Are medical points with facilities located throughout the workplace?Y Y

Does the company provide facilities when working away from the main office?Y Y

Are qualified emergency first aid personnel easily identified e.g. badges / different

coloured uniform / pictures on the notice boards? (Specify quantity of personnel) Y Y

Are subcontractors/temporary/agency workers allowed to use these facilities?Y Y

Question Evidence:

First aid boxes were kept at the company's premises. First Aiders were available at all

premises including first aid facilities. The facilities were assessed as satisfactory.

Documents Presented

First aider training expires 28/05/2020.


7.12 Does the company have arrangements in place for investigating and reporting of

Accidents and Incidents and Near Misses in their worksites? 3 3


Does the company have a nominated person who reports all accidents and incidents to

government agencies and where applicable a corporate Head Office? Y Y

Does the company maintain records of accidents and incidents (This includes safety &

environmental incidents)? Y Y

Does the company have a documented process for undertaking investigations into

accidents/incidents and near miss occurrence? Y Y

Does the company produce and analyse Accident and Incident Statistics?N N

Can the company demonstrate that lessons have been learned and applied from

incidents? The auditor should record what improvements have been implemented. Y Y

Has the company had any prohibition or Improvement notices in the last 5 years?

(auditor to check http://www.hse.gov.uk/notices/ as part of audit) N N

Has the company had any HSE Prosecutions within the last 5 years?

(auditor to check http://www.hse.gov.uk/prosecutions/ as part of audit) N N

Jump to Accident and Incident Statistics

Question Evidence:

The arrangements for accident and incidents reporting were detailed in the safety

management system manual. The General Manager or Site Manager was responsible for

undertaking investigations in the event of an accident and records were made available.

Documents Presented

Incident reporting procedure from H&S policy manual dated 2017.

Section Score31 25


8.0 Occupational Health

8.1 Does the company have a nominated person who has responsibility for

occupational health / industrial hygiene? 3

Does this person have defined responsibilities as part of the management system?Y

Does the company use the services of a third party (Can be private or government

operated facility) medical centre/hospital for the delivery of occupational/worker health

services?Y

If an accountable person is not identified within the company, what systems are in place

to ensure the health and hygiene of employees? NA

Question Evidence:

Senior management were responsible for implementing the occupational health

procedures and co-ordinating any medicals. Health monitoring was part of this.

Documents Presented

H&S manual dated 2017.

CQ8.2 Does the company undertake any Health (medical) Surveillance

screening/monitoring/testing of their workforce? 2

Is the screening part of the pre employment selection criteria?N

Is testing undertaken (either pre employment or periodic) because of the type of work

the company undertakes e.g. working with chemicals or noisy environment? N

Can it be confirmed that the company have implemented controls to prevent workers

being exposed to harmful chemical, biological and physical agents/substances/materials

that exceed the minimum legal exposure limits?Y

Does the company and subcontractors have documented processes for ensuring

employee fitness for work? Do requirements include Drug and Alcohol testing? Y

Question Evidence:

Health monitoring activities were not fully evident although formal communication of the

drugs and alcohol policy was evident. DSE assessments were also not carried out.

Minor non-compliance: The use of health questionnaires and DSE assessments were

not evident.

Documents Presented

Employee Handbook includes Alcohol And Drugs Policy.

Section Score5


9.0 Emergency Planning

9.1 Does the company have a controlled process for the identification and

implementation of emergency arrangements? 3 3

Does the company have controlled processes for the identification and implementation of

work site specific emergency arrangements? Y Y

Are site specific emergency arrangements communicated to all applicable personnel?Y Y

Can the company demonstrate that they have tested the effectiveness of their emergency

arrangements? Y Y

Does the company mandate minimum competency levels and minimum resource levels

within the documented emergency arrangements? Y Y

Has the company quantified minimum medical provision and support within the

emergency plan? Y Y

Can the company demonstrate that they provide visitors/external auditors/ contractors

who visit their site with specific information on site safety hazards including emergency

evacuations?Y Y

Is there a programme in place that ensures that all emergency (fire and evacuation)

equipment is checked regularly by a competent person? (This can be a third party) Y Y

Question Evidence:

The company had the following emergency measures: fire equipment checks, fire risk

assessments, inductions and procedures.

Documents Presented

Fire risk assessment dated July 2017.

Emergency procedure for main offices.

Fire drill dated 19/05/2017.

Section Score3 3


10.0 Site Security

10.1 Does the company ensure the security of the work site both during work and

non working hours? 3 3


The auditor will record a description of the processes used e.g. fencing / patrols / lighting

/ alarms

Question Evidence:

The company stated that their premises had secured access at the head office which had

a high perimeter fence buzzer entry and their was an intruder alarm installed.

Documents Presented

10.2 Does the company utilise CCTV to monitor workplace security?3 3


Confirm the numbers of cameras on site and if fixed or mobile type used.Y Y

Are government permits required and in place for CCTV systems?N N

Question Evidence:

The company stated that their premises had secured access and there were Landlord

CCTV cameras installed near the main offices.

Documents Presented


10.3 Are security personnel employed directly by the company or engaged via a third

party and how are they distinguishable from other members of the workforce? 3 3


Do they undertake programmed patrols of all work sites?NA NA

How does the company ensure the competency and legitimacy of security personnel and

does this include Security Industry Association (SIA) licensing? NA NA

Can the company demonstrate that site based security personnel have been inducted to

the operational working sites that they patrol? NA NA

Question Evidence:

The company do not use security personnel through internal employees or third party

service providers at any location.

Documents Presented

Section Score9 9


11.0 Business Continuity

11.1 Does the Company have formal arrangements in place for the implementation of

a business continuity management plan? 2

Is a formal plan in place? (Specify if localised arrangement only or part of multinational

group) N

Has the plan been subject to trial or simulation?N

Does the plan cover areas that could result in the total loss of operations? (such as

terrorist threats, natural disasters, power cuts, etc.) N

Can the company demonstrate all reasonable emergency situations have been identified?

(Specify if this has been documented and by whom) N

Is the documented plan subject to a regular review? (please detail time frame)N

Has the company appointed an individual with responsibility for this area?Y

Question Evidence:

The General Manager explained how the company would deal with a business risk

scenario through engaging with their parent company. Although a formal business

continuity plan was not established.

Minor non-compliance: A formal business continuity plan was not established.

Documents Presented

Section Score2


12.0 Environmental Management

12.1 Does the company have an environmental policy statement?2


Is the policy statement signed and endorsed by the most senior management

representative? Y

Does the policy relate to the company activities? N

Is it displayed in a prominent position or made available to all interested parties?N

Commit the company to a continuous improvement programme and ensures compliance

with all relevant environmental legislation or industry guidance? Y

Does it identify how environmental issues will be communicated?Y

Is the period for review detailed?N

Question Evidence:

The company provided evidence of their policy statement and this was signed by the MD.

This policy statement was not detailed when it was last reviewed or if it was made

available to the public on request.

Minor non-compliance: The environmental policy statement was not detailed when it

was last reviewed or if it was made available to the public on request and appeared

generic.

Documents Presented

Environment policy statement.


12.2 Are the company’s environmental management systems documented?2


Does the system document the company's environmental responsibilities?Y

Are details of the communication process detailed?Y

Are responsibilities clearly defined?Y

Is there an inspection and audit regime?Y

Are emergency procedures detailed?Y

Is there written sections on waste and recycling?Y

Does the company have a policy on sourcing materials / procurement strategy?Y

Is there written sections on the management of subcontractors?Y

Does the system detail the measures to be taken in the design process?N

Does the systems establish legal requirements including creation and maintenance of a

register of legislation / changes to legislation? Y

Question Evidence:

The company had procedures which defined the organisation and system of operational

procedures. There were also procedures for identifying changes to legislation and

environmental responsibilities were documented.

Minor non-compliance: The environmental management system did not clearly take

into account design process controls.

Documents Presented

EMS manual dated 2017.

Legal register dated 2017.

12.3 Does the company utilise a variety of sources to ensure the content of the

environmental management system? 3


In House expertise?Y

External consultancy?Y

Subscription services?Y

Government agencies / Local /Municipal Authorities?N

Question Evidence:

The company had access to an external consultant. Subscription services and updates are

received from the environment agency.

Documents Presented

Peninsula.


12.4 Does the company manage the Aspects and Impacts associated with their scope

of services? 2


Are these processes documented in the form of a register or similar?Y

Does the company have a formal communication process for communicating the content

of the register? Y

Is there evidence of a periodic assessment and evaluation of the content?N

Question Evidence:

The company aspects and impacts register was reviewed and this included appropriate

basic control measures.

Minor non-compliance: The aspects and impacts register did not contain expansive

control measures and did not contain the Assessors name.

Documents Presented

Environmental aspects reviewed in a register dated 2017.

CQ12.5 Does the company have control measures in place to reduce/remove identified

environmental risk? 2 3


Does the company use data from maintenance programmes / operations to enhance

controls processes? Y Y

Does the Internal auditing regime monitor the control measures in place?N Y

Are inspections received from government agencies?N N

Question Evidence:

Internal inspections were planned as being undertaken by the General Manager and these

were integrated with the safety inspections. There were no internal auditing schedules or

system based audits for the management system hence the score drop for the MSE

section.

Minor non-compliance: Specific internal environmental audit programmes and audits

were not always carried out.

Documents Presented

Period inspection reports dated May 2017.

Section Score 11 3


13.0 Carbon Management

13.1 Does the company quantify and report their Greenhouse Gas (GHG) emissions?3


Can the company provide the total emissions, in terms of tCO2e (tonnes of carbon dioxide

equivalent), that they were responsible for emitting over their standard reporting year? NA

Does the company capture indirect emissions as well as direct emissions e.g. supply

chain? NA

Is this a definitive answer e.g. 2008 calendar year: 12,100 tCO2e?NA

Is the figure published in the form of a standard report, spreadsheet or for larger

companies, published in a CSR or annual report? NA

In the question evidence, please detail the person or persons responsible for reporting?NA

Question Evidence:

The company are not legally required to report their Greenhouse Gas (GHG) emissions

due to the size and turnover of the organisation. No utility client had requested the

company to undertake this.

Documents Presented

13.2 Are follow up actions set in place as part of the monitoring and measuring

process? 3


Are new targets set after each review period?NA

Are the follow up actions communicated to all employees?NA

If targets are not achieved, are strategies set in place in order to meet them?NA

Question Evidence:

The company were not required to monitor and measure their carbon foot print and

emissions.

Documents Presented

Section Score6


14.0 Waste Management

14.1 Does the company have processes or systems in place to manage waste

(Produced as a result of their activities)? 3 3


Recycling initiatives?Y Y

Are the systems formal?Y Y

Question Evidence:

The company stated that some waste was segregated for potential recycling. In addition

minimising of waste was done through careful and efficient use of all materials.

Documents Presented

EMS manual dated 2017.

CQ14.2 Does the company ensure that it disposes of all its waste in a legal and proper

manner? 3 3


Does the company use a formal transfer note process? (Specify how this works)Y Y

Do they use licensed waste companies and licensed waste carriers? (Specify if company

has to be subject to government licensing programme) Y Y

Do they have access to up to date waste legislation?Y Y

If burying the waste are they using authorised sites?Y Y

Transfer to authorised/licensed waste management company?Y Y

Where applicable can the company demonstrate that it complies with the Waste Electrical

and Electronic Equipment (WEEE) Regulations 2013. Y Y

Question Evidence:

The company stated they use the services of registered waste carriers and records of

licenses were made available. Records were retained in a specific environmental waste

records file.

Documents Presented

Robert Beck & Sons waste transfer notes viewed dated 15/10/2016.

Waste skips reviewed at site and segregation facilities in place and transfer notes.


14.3 Does the company store any waste material on site?3 3


Are they classified as Hazardous?Y Y

Are they classified as Non Hazardous?Y Y

Are they classified as non flammable?Y Y

Are they classified as flammable?Y Y

Are there quarantine areas to prevent any cross contamination?Y Y

If liquid are there adequate spill preventions / containment / spill kits?Y Y

Are inspections undertaken on the controls?Y Y

Question Evidence:

The company stated that waste materials were stored in a segregated area and hazardous

waste was segregated.

Documents Presented

Inspection report viewed dated May 2017.

Section Score9 9


15.0 Selection and Management of the Supply Chain

15.1 Has the company appointed a management representative with overall authority

for subcontractor / supplier selection and management? 2


Detail the job title within the question evidence.Y

Are deputies within the company in the absence of the representative?Y

Does the company have a forum, group or committee to review contractor/ supplier

performance? Y

Does the company use a due diligence process e.g. double signatures or similar before a

company can be employed contractually. N

Question Evidence:

The Managing Director and General Manager had the functional responsibility for supplier

management and approval. Evidence of an contractor supplier questionnaire was sampled

although these did not include a signed off by senior management.

Minor non-compliance: Contractor supplier questionnaires were sampled although

these did not include a signed off by internal senior management.

Documents Presented


HSE questionnaire version 1.0 HS14.


15.2 Does the company ensure effective management of their supply chain?3


Does the company maintain an approved supplier list?Y

Has the company got a process for the evaluation/ selection of contractors/ suppliers, to

include PQQ, pre start H&S inspections of activities? Y

Has the company identified the minimum levels of insurance applicable and required to be

held by its subcontractors? Y

Does the company specify any accreditations/ requirements e.g. UVDB,

BuildingConfidence? Y

Has the company identified the minimum quality, safety and environmental controls

applicable and required to be held by its supply chain? Y

Is there confirmation of subcontractor competency assurance? Y

Question Evidence:

The company used a range of suppliers and a basic supplier questionnaire was in place.

Documents Presented

Approved suppliers lists.

HSE questionnaire version 1.0 HS14.

15.3 Does the company undertake any reviews of their supply chain performance?3


Is there a review mechanism?Y

Is there a method for recording reviews?Y

Is there a process for rectifying faulty work?Y

Is there a process to prevent contractors/ suppliers with poor performance continuing to

work for the company, or to instigate improvements? Y

Does the company have a mechanism for periodic monitoring of subcontractors

insurances, licenses and professional memberships? Y

Does the company capture / analyse subcontractors accidents / incidents statistics and

reports? Y

Does the company have a process to investigate contractor/ supplier, Accidents/

Incidents and track actions? Y

Question Evidence:

There were reviews carried out on all suppliers as detailed in the management review

meeting dated June 2017.

Documents Presented

Management review meeting dated June 2017.


15.4 Does the company assess/audit/inspect their supply chain?2

First TierN

Second TierN

Third TierNA

Fourth TierNA

Entire supply chainNA

Are audit/inspection personnel employed or are 3rd party auditors used?

Does the company have a process for the recording and monitoring of any corrective

actions raised at subcontractor/supply audits? Y

Question Evidence:

Desktop annual reviews of supplier information and management reviews were the main

source of formal checks on suppliers.

Minor non-compliance: The company does not currently carry out any inspections or

audits of their supply chain.

Documents Presented

Management review meeting dated June 2017.

Section Score10


16.0 Sourcing of goods and products

16.1 Can the company demonstrate that they have put in place formal arrangements

for the identification, mitigation and prevention of Counterfeit, Fraudulent and

Suspect Items (CFSI)?3

Are arrangements integrated into the company's management processes / procedures?N

Has the company established measures to ensure that its staff are aware of the risks of

CFSI and understand and support the company's mitigation methods? N

Has the company taken measures to raise awareness throughout all levels of its supply

chain that there are parties who might wish to substitute CFSI for genuine items or

services for commercial gain. N

Has the company deployed assurance methods to ensure material and component

traceability back to source suppliers, including positive material identification, destruction

testing methods by third party specialist organisations, including sampling of proprietary

high risk items (i.e. bolts and fasteners)?Y

Where examples of CFSI have been identified have appropriate remedial actions have

been taken? (i.e. quarantine arrangements, investigation and dispose of CFSI and

information shared within the company, licensee organisation, supply chain and wider

industry as appropriate to support learning, prevent use and encourage remedial

measures?

NA

For companies working in the Nuclear Industry, where examples of CFSI have been

identified have these been notified to the Office of Nuclear Regulation (ONR)? NA

Question Evidence:

Their was no specific awareness to the above questions regarding CFSI although the

company do not work in the nuclear industry.

Observation: There was no specific awareness of CFSI although the company do not

work in the nuclear industry.

Documents Presented


16.2 Does the company have a policy to procure fairly traded goods where available?3

Auditor to record details.NA

Question Evidence:

The company does not procure fair trade goods in relation to the services provided. The

company will source goods where practicable.

Documents Presented

SHEQ policy manual dated 2017.

16.3 Does the company work with its top level suppliers to prevent bribery &

corruption throughout its supply chain? 2

Auditor to record details.Y

Question Evidence:

The company did not have a formal process to validate how they worked to prevent anti-

bribery with 3rd parties including the supply chain as no live policy was in place and no

evidence this was requested within their supplier questionnaire.

Minor non-compliance: The company did not have a formal process to validate how

they worked to prevent anti-bribery with their supply chain.

Documents Presented

Draft anti-bribery policy.


16.4 If the company handles materials from legal and sustainable sources, can they

demonstrate chain of custody certification? 3


If purchasing raw materials is there a mandated requirement to use materials that

possess a Chain of Custody e.g. Forestry Stewardship Council (FSC) timber. Y

Do delivery notes contain a chain of custody certificate? (Specify if this is subject to

verification prior to use) Y

Question Evidence:

The company did purchase raw materials which were subject to a chain of custody

certification and records were retained within the office invoice files.

Documents Presented

Approved suppliers list.


16.5 Can the company demonstrate that they actively assess their supply chain for

the potential of child labour being involved in the work process? 3

Can the company demonstrate that they ask their suppliers about child labour in the

supply chain? Y

If they are sourcing goods where there is a higher probability of children being involved

in the work process which can include both forced labour / contractual labour via schools

etc.; what processes do they have in place to mitigate this? NA

Question Evidence:

The company confirmed that they only bought supplies from the UK. The company were

required to use the clients suppliers.

Documents Presented

Section Score14


17.0 Use of Work Equipment, Vehicles and Machines

CQ17.1 Does the company have arrangements in place for ensuring that all plant, hand

tools and equipment are approved prior to use? 3 3

The Auditor should establish the existence of a documented process for the maintenance

of plant and tools and that maintenance arrangements and records include:

Does the company retain any calibration records?Y Y

Does the company have a process for reporting and repairing defects on plant and

equipment? Y Y

Does the company produce a scheduled maintenance plan for each individual plant item?Y Y

Does the company use internal staff to maintain and inspect equipment?Y Y

Are statutory inspections undertaken and valid Test/Inspection Certificates issued by a

third party? Y Y

Question Evidence:

The company had procedures which were adopted for all equipment to be used for formal

examination. There was a folder which contained all equipment records and dates of

calibration. The processes were described by the General Manager.

Documents Presented

Calibration equipment folder reviewed dated 2017.

Calibration of torque serial no: 15007 calibrated dated 06/04/2017.


17.2 If the company uses equipment from a third party hire company (short or long

term), does the company ensure that the equipment is fit for purpose? 3 3


Does the company have a process for verifying that equipment supplied is fit for purpose?Y NA

Does the company request calibration records when equipment arrives on site?Y NA

Does the company retain copies of certificates of conformity for all tested equipment?Y NA

Question Evidence:

Hired-in plant and equipment was monitored centrally at the head office. Copies of

inspection certificates were retained with the hired equipment. There was no hired

equipment at site.

Documents Presented

Invoices dated 2017.

CQ

17.3 If the company uses cranes (Fixed or mobile) or other lifting equipment, do they

have processes in place to discharge their mandatory checks/thorough

examinations?3 3

Could the auditor verify that records had been completed and maintained?Y Y

Are checks/examinations completed by competent/capable persons?Y Y

Can the company demonstrate compliance with the relevant lifting/safety regulations of

their country of operation? Y Y

Question Evidence:

Lifting plant and equipment were subject to statutory inspections. Copies of inspection

certificates were retained. Staff were required to complete plant and equipment

inspections which were also recorded on file.

Documents Presented

LOLER examination dated 23/05/2017 for an overhead crane serial no: L14A11.

Section Score9 9


18.0 Insurance and Warranty

18.1 Can the company demonstrate that it has adequate insurance to cover not only

its scope of works, also its workforce and surrounding environment? 3

Name of the insurance company

Policy Numbers

Covers for each claim (Specify category of insurance and currency e.g. US$)

Expiry Date

Does the Cover include scope of operations? Domestic or International coverage / group

or localised coverage. Y

Question Evidence:

The company provided evidence of their insurance coverage and these were all valid and

in date.

Documents Presented

Insurance certs (UVDB PQQ).

18.2 Can the company demonstrate what form of warranty or guarantee they provide

as part of their service package? 3

The auditor shall record the description of the process offered including timescales, any

restrictions placed upon customers and if they provide recalls on any products they have

installed/produced.Y


Policy Numbers


Expiry Date


or localised coverage. Y

Question Evidence:

The company provide a 12 months guarantee for the services provided.

Documents Presented


18.3 If the insurance cover has been issued to a parent or holding company, how is

this process managed in the event of a claim? 3

If supplier operates in a different country from that of their Head Office is the currency of

the policy different? NA

Can the company demonstrate there are no ‘excesses’ or ‘restrictions’ that limit the

company’s indemnity? NA

If the Policy has been issued to a ‘Parent’ or Holding Company, is this discharged to cover

the activities of the supplier? NA


Policy Numbers


Expiry Date


or localised coverage. NA

Question Evidence:

The company insurance was not provided by a Parent company.

Documents Presented

Section Score9

END


Key Performance Indicators (KPIs)

EXPOSURECurrent

YearYear -1 Year -2 Year -3 Year -4

Total Manhours worked 20800 31200 29120 29120 24960

SAFETYCurrent


Fatalities 0 0 0 0 0

HSE Reportable Injuries 0 0 0 0 0

Lost time incidents (1-7 days) 0 0 0 0 0

Incidents requiring medical treatment (MTI) 0 1 0 2 0

Incident requiring first aid 0 3 0 4 3

Dangerous Occurrences 0 0 0 0 0

Near Hits/Misses 0 0 0 0 0

HSE/HSA or equivalent improvement notices 0 0 0 0 0

HSE/HSA or equivalent prohibition notices 0 0 0 0 0

HSE/HSA or equivalent prosecutions 0 0 0 0 0

ENVIRONMENTCurrent


Minor Non-reportable incidents 0 0 0 0 0

Reportable incidents 0 0 0 0 0

Enforcement action i.e. Warning letters, prosecutions0 0 0 0 0